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under section 280F, and strict substantiation is therefore
required. Sec. 274(d). No deduction is allowed for any travel
or transportation expense unless the taxpayer substantiates by
adequate records or by sufficient evidence corroborating the
taxpayer’s own statement the amount of the expense, the mileage
for each business use of the automobile and the total mileage for
all use of the automobile during the taxable period, the date of
the business use, and the business purpose for the use. Sec.
1.274-5T(b)(6), Temporary Income Tax Regs., 50 Fed. Reg. 46016
(Nov. 6, 1985). Adequate records include the maintenance of an
account book, diary, log, statement of expense, trip sheets,
and/or other documentary evidence, which, in combination, are
sufficient to establish each element of expenditure or use. Sec.
1.274-5T(c)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46017
(Nov. 6, 1985).
Taxpayers may use a standard mileage rate established by the
Internal Revenue Service in lieu of substantiating the actual
amount of the expenditure. See sec. 1.274-5(j)(2), Income Tax
Regs. The standard mileage rate is generally multiplied by the
number of business miles traveled. See Rev. Proc. 2002-61, 2002-
2 C.B. 616 (in effect for transportation expenses incurred during
2003). The use of the standard mileage rate establishes only the
amount deemed expended with respect to the business use of a
passenger automobile. Sec. 1.274-5(j)(2), Income Tax Regs. The
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